H.R. 5349

TAS Act

Sponsor: Nathaniel Moran

1 cosponsor
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Official summary

Written by the Congressional Research Service.

Tax Court Improvement Act

This bill expands the authority of the U.S. Tax Court to issue subpoenas, authorizes the Tax Court to extend certain petition deadlines, and makes other changes related to Tax Court procedures.

The bill authorizes the Tax Court to issue subpoenas compelling the production of documents and other items from a litigant or witness for evidentiary or discovery purposes (whether or not it is in connection with a scheduled hearing). (Under current law, the Tax Court may issue subpoenas only to compel the attendance and testimony of witnesses and the production of evidence at a scheduled hearing or deposition.)

The bill authorizes the Tax Court to extend (or toll) the deadline to file a Tax Court petition contesting an Internal Revenue Service (IRS) deficiency notice if it is equitable to do so (known as equitable tolling). Further, under the bill, the dismissal of a petition contesting an IRS deficiency notice because the petition is not filed before the deadline and equitable tolling is denied is not treated as a decision of the Tax Court. This allows a subsequent claim to be filed in U.S. district court if certain conditions are met.

The bill also

  • expands the type of Tax Court proceedings for which special trial judges may be appointed,
  • authorizes Tax Court special trial judges to impose fines up to $5,000 and up to 30 days in jail for contempt of court, and
  • requires Tax Court judges and special trial judges to recuse themselves in certain circumstances.

Text of the bill

Expand all
Sec. 1. Short title; etc Changed · Sep 30

Where this section came from

  1. Sep 15, 2025 · Introduced in House Referred to House Committee on Ways and Means, Sep 15
  2. Oct 3, 2025 · Reported in House Marked up by House Committee on Ways and Means, Sep 17 Reported by House Committee on Ways and Means, Oct 3 Committee members' individual votes aren't in our records.
  3. Sep 30, 2026 · Engrossed Amendment Senate S.Amdt. 6848: To amend the title. Official page › S.Amdt. 6847: In the nature of a substitute. Official page ›
What changed in the text

(a) Short title. This Act may be cited as the Tax Taxpayer Court Assistance Improvement and Service Act or the TAS Act .

… 1 unchanged passage …

(c) References to Secretary. For purposes of this Act, the term Secretary means the Secretary of the Treasury or the Secretary's delegate. (d) Table of contents. The table of contents of this Act is as follows: Sec. 1. Short title; etc. TITLE I—Tax Administration and Customer ServiceSec. 101. Digitization of tax returns and correspondence. Sec. 2 102 . Establishment of dashboard to inform taxpayers of backlogs and wait times.Sec. 103. Expansion of electronic access to information about returns and refunds.Sec. 104. Expansion of callback technology.Sec. 105. Expansion of online accounts.Sec. 106. Automation of refund offset bypass.Sec. 107. Installment agreement fees eliminated for certain individuals.Sec. 108. Individuals facing economic hardships informed of collection alternatives.Sec. 109. Quarterly notices to certain taxpayers with delinquencies.Sec. 110. Low-income taxpayer clinic funding unlocked.Sec. 111. Chief Counsel reviews of offers-in-compromise streamlined.Sec. 112. Modification of procedural requirements for penalties and disallowance periods.Sec. 113. Return of amounts collected by IRS in excess of accepted offer-in-compromise amount.Sec. 114. Extension of period for return of amounts subject to wrongful levy.Sec. 115. Reports to Congress.TITLE II—American Citizens AbroadSec. 201. Report on combined tax and foreign bank and financial account reporting.Sec. 202. Study and reports on simplification.Sec. 203. Extension of time for persons outside of the United States to request abatement of math error.Sec. 204. Clarification of assessment authority; pre-assessment appeals of foreign information return penalties.Sec. 205. Repeal of due date requirements for certain information returns relating to foreign gifts and trusts.TITLE III—Judicial ReviewSec. 301. Authorization of subpoenas before hearings to facilitate settlements.Sec. 3 302 . Clarification of Tax Court authority to order relief from a judgment or order.Sec. 303. Authorization of special trial judges to hear additional cases and address contempt.Sec. 4 304 . Disqualification of judges and special trial judges.Sec. 5 305 . Notice and review with respect to multi-year bans on claiming credits.Sec. 306. Authorization of de novo review of innocent spouse relief by the Tax Court and other courts.Sec. 307. Clarification of certain court filing deadlines.Sec. 308. Clarification of Tax Court jurisdiction to apply determine equitable tax tolling liability in deficiency collection due process appeals.Sec. 309. Authorization of the Tax Court to issue refunds in collection due process cases. Sec. 310. Authorization of the Tax Court to hear suits for refunds or credits.Sec. 311. Authorization to allow claims for refund in certain cases where full tax not paid.Sec. 312. Adjustment of threshold for small disputes.TITLE IV—Office of the Taxpayer AdvocateSec. 401. NTA authorization to direct hire attorneys.Sec. 402. NTA authorization to make personnel decisions.Sec. 403. Access to Internal Revenue Service information, legal advice, and meetings.Sec. 404. Repeal of limitation period suspension for taxpayers seeking assistance from TAS.Sec. 405. Operations to assist taxpayers experiencing hardships during lapse in appropriations.TITLE V—Tax Return PreparersSec. 501. Penalties for tax return preparers who improperly alter returns.Sec. 502. Ensuring the use of valid preparer identification numbers and electronic filing identification numbers.Sec. 503. Penalties for improper tax preparation or misappropriation of refunds.Sec. 504. Authority to deny, revoke, or suspend preparer tax identification numbers.TITLE VI—AppealsSec. 601. Authorization for Office of Appeals to hire attorneys.Sec. 602. Authorization for Office of Appeals to direct hire certain individuals.Sec. 603. Responses to claims for refund required; appeal of claims for refund authorized.Sec. 604. Appeals of returned offers.Sec. 605. Purposes and duties of Independent Office of Appeals; right of appeal clarified.TITLE VII—WhistleblowersSec. 701. Standard and scope of review of whistleblower award determinations.Sec. 702. Exemption from sequestration.Sec. 703. Whistleblower privacy protections.Sec. 704. Modification of IRS whistleblower report.Sec. 705. Interest on whistleblower awards.Sec. 706. Correction regarding deductions for attorney's fees.TITLE VIII—HostagesSec. 801. Postponement of tax deadlines for hostages and individuals wrongfully detained abroad.Sec. 802. Refund and abatement of penalties and fines paid by eligible individuals.TITLE IX—Small BusinessesSec. 901. Implementation of voluntary withholding agreements for payments to independent contractors.Sec. 902. Extension of mailbox rule to electronic submissions and payments.Sec. 903. Specificity of third-party contact notices.Sec. 904. Modification of estimated tax rules for farmers and fishermen.Sec. 905. Business child care liaison.TITLE X—MiscellaneousSec. 1001. Authority for redisclosure of certain tax information related to education loans to the Congressional Budget Office.Sec. 1002. Authorization to require large partnerships to file on magnetic media.Sec. 1003. Limitation period not extended for victims of preparer fraud.Sec. 1004. Technical amendment related to the Disaster Related Extension of Deadlines Act.Sec. 1005. Time for filing certain information returns.Sec. 1006. Modifications to penalties for unauthorized disclosures of taxpayer information.

What is a markup?

A markup is a committee meeting where members go through a bill and vote on changes before sending it to the full chamber.

(a) Short title. This Act may be cited as the Taxpayer Assistance and Service Act or the TAS Act.

(b) Amendment of 1986 code. Except as otherwise expressly provided, whenever in this Act an amendment is expressed in terms of an amendment to a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.

(c) References to Secretary. For purposes of this Act, the term Secretary means the Secretary of the Treasury or the Secretary's delegate.

(d) Table of contents. The table of contents of this Act is as follows: Sec. 1. Short title; etc.TITLE I—Tax Administration and Customer ServiceSec. 101. Digitization of tax returns and correspondence.Sec. 102. Establishment of dashboard to inform taxpayers of backlogs and wait times.Sec. 103. Expansion of electronic access to information about returns and refunds.Sec. 104. Expansion of callback technology.Sec. 105. Expansion of online accounts.Sec. 106. Automation of refund offset bypass.Sec. 107. Installment agreement fees eliminated for certain individuals.Sec. 108. Individuals facing economic hardships informed of collection alternatives.Sec. 109. Quarterly notices to certain taxpayers with delinquencies.Sec. 110. Low-income taxpayer clinic funding unlocked.Sec. 111. Chief Counsel reviews of offers-in-compromise streamlined.Sec. 112. Modification of procedural requirements for penalties and disallowance periods.Sec. 113. Return of amounts collected by IRS in excess of accepted offer-in-compromise amount.Sec. 114. Extension of period for return of amounts subject to wrongful levy.Sec. 115. Reports to Congress.TITLE II—American Citizens AbroadSec. 201. Report on combined tax and foreign bank and financial account reporting.Sec. 202. Study and reports on simplification.Sec. 203. Extension of time for persons outside of the United States to request abatement of math error.Sec. 204. Clarification of assessment authority; pre-assessment appeals of foreign information return penalties.Sec. 205. Repeal of due date requirements for certain information returns relating to foreign gifts and trusts.TITLE III—Judicial ReviewSec. 301. Authorization of subpoenas before hearings to facilitate settlements.Sec. 302. Clarification of Tax Court authority to order relief from a judgment or order.Sec. 303. Authorization of special trial judges to hear additional cases and address contempt.Sec. 304. Disqualification of judges and special trial judges.Sec. 305. Notice and review with respect to multi-year bans on claiming credits.Sec. 306. Authorization of de novo review of innocent spouse relief by the Tax Court and other courts.Sec. 307. Clarification of certain court filing deadlines.Sec. 308. Clarification of Tax Court jurisdiction to determine tax liability in collection due process appeals.Sec. 309. Authorization of the Tax Court to issue refunds in collection due process cases.Sec. 310. Authorization of the Tax Court to hear suits for refunds or credits.Sec. 311. Authorization to allow claims for refund in certain cases where full tax not paid.Sec. 312. Adjustment of threshold for small disputes.TITLE IV—Office of the Taxpayer AdvocateSec. 401. NTA authorization to direct hire attorneys.Sec. 402. NTA authorization to make personnel decisions.Sec. 403. Access to Internal Revenue Service information, legal advice, and meetings.Sec. 404. Repeal of limitation period suspension for taxpayers seeking assistance from TAS.Sec. 405. Operations to assist taxpayers experiencing hardships during lapse in appropriations.TITLE V—Tax Return PreparersSec. 501. Penalties for tax return preparers who improperly alter returns.Sec. 502. Ensuring the use of valid preparer identification numbers and electronic filing identification numbers.Sec. 503. Penalties for improper tax preparation or misappropriation of refunds.Sec. 504. Authority to deny, revoke, or suspend preparer tax identification numbers.TITLE VI—AppealsSec. 601. Authorization for Office of Appeals to hire attorneys.Sec. 602. Authorization for Office of Appeals to direct hire certain individuals.Sec. 603. Responses to claims for refund required; appeal of claims for refund authorized.Sec. 604. Appeals of returned offers.Sec. 605. Purposes and duties of Independent Office of Appeals; right of appeal clarified.TITLE VII—WhistleblowersSec. 701. Standard and scope of review of whistleblower award determinations.Sec. 702. Exemption from sequestration.Sec. 703. Whistleblower privacy protections.Sec. 704. Modification of IRS whistleblower report.Sec. 705. Interest on whistleblower awards.Sec. 706. Correction regarding deductions for attorney's fees.TITLE VIII—HostagesSec. 801. Postponement of tax deadlines for hostages and individuals wrongfully detained abroad.Sec. 802. Refund and abatement of penalties and fines paid by eligible individuals.TITLE IX—Small BusinessesSec. 901. Implementation of voluntary withholding agreements for payments to independent contractors.Sec. 902. Extension of mailbox rule to electronic submissions and payments.Sec. 903. Specificity of third-party contact notices.Sec. 904. Modification of estimated tax rules for farmers and fishermen.Sec. 905. Business child care liaison.TITLE X—MiscellaneousSec. 1001. Authority for redisclosure of certain tax information related to education loans to the Congressional Budget Office.Sec. 1002. Authorization to require large partnerships to file on magnetic media.Sec. 1003. Limitation period not extended for victims of preparer fraud.Sec. 1004. Technical amendment related to the Disaster Related Extension of Deadlines Act.Sec. 1005. Time for filing certain information returns.Sec. 1006. Modifications to penalties for unauthorized disclosures of taxpayer information.

I Tax Administration and Customer Service

II American Citizens Abroad

III Judicial Review

IV Office of the Taxpayer Advocate

V Tax Return Preparers

VI Appeals

VII Whistleblowers

VIII Hostages

IX Small Businesses

X Miscellaneous